Lenders to Learn about UDAAP From CFPB Exams, Combined Disclosure Rule Raises Many Questions
August 2, 2012
One of the many concerns mortgage lenders have with the powerful and still largely untested Consumer Financial Protection Bureau is the expanded standard of unfair, deceptive and abusive acts and practices created by the Dodd-Frank Act and how the CFPB is going to enforce it. Unfortunately, theyre more likely to learn about it on the fly during the examination process than they are in advance through careful, formal rulemaking or supervisory guidance, according to one of the presenters during an Inside Mortgage Finance webinar last week on the CFPBs regulatory and supervisory landscape. What I think youre seeing develop here is examination beyond regulation, and the CFPBs examination authority and supervision authority goes beyond...